Hotels and other entities should expect unions to routinely use OSHA citations as an organizing tool and a way to harass hospitality employers. In a recent Hospitality Update, we described a May 12 Houston Chronicle article complaining about the allegedly high rate of ergonomic injuries suffered by hotel employees. [See "Multiple Embarrassing OSHA Citations: The Next Union Organizing Tactic?" by Howard Mavity. Hospitality Update, June, 2010.]

The newspaper cited a February, 2010, study published in the American Journal of Industrial Medicine, arguably sponsored by UNITE-HERE. Initially, the Union used the study to create a wedge between employees and employers. The Union recently upped the ante by filing OSHA complaints at eight hotels in Illinois, California, Indianapolis, and Honolulu. The complaints, filed on Nov. 8, 2010, all allege housekeeper injuries. The employer, Hyatt, responded that the OSHA complaints were filed against hotels where the company was trying to negotiate a new agreement or in markets where the union's main goal was to increase membership.

These complaints present at least seven lessons for employers...